Tax, treaty, FEMA, and investment — handled together for clients whose lives sit across two tax jurisdictions.
Request a Consultation →An NRI client's India file usually has half a dozen moving pieces — residential status, rental income, capital gains on shares, NRO interest, mutual-fund holdings, repatriation, and the property the family still owns in Delhi. Each piece carries its own tax, FEMA, and reporting obligation, and most practices split the file across two or three desks. I try to keep it on one.
The CFA Charter adds a dimension that's rare in CA practice — Investment Policy Statement work, asset allocation across geographies, and a markets-informed view on PMS, mutual funds, and direct equity exposure. For a number of clients the planning conversation begins with the tax file and ends with a re-thought portfolio.
Residential status determination under Section 6 of the Income-tax Act, 1961 — carried forward as Section 6 of the Income-tax Act, 2025 — including the post-2020 'Deemed Resident' provisions for Indian citizens earning above ₹15L from Indian sources. ITR filings under Section 139 of the 1961 Act (Section 263 of the 2025 Act) for NRIs, including capital gains on shares and immovable property, rental income, NRO interest, and dividend treatment.
Treaty analysis for clients in the US, UK, UAE, Singapore, Mauritius, Canada, and Australia. Tax Residency Certificate (TRC) acquisition guidance, Form 10F filings, and Section 90 / 90A claim documentation under the 1961 Act (corresponding to Sections 159 / 160 of the Income-tax Act, 2025). Capital gains shielding under specific treaties (where still available post-2017).
NRE / NRO / FCNR account structuring, repatriation under the USD 1 million NRO limit, Form 15CA / 15CB certification, and RBI reporting for outbound investments and ODI. FEMA compliance for ESOPs received from foreign employers and Indian companies of NRIs.
As an incidental adjunct to the tax and FEMA workstream — and only for existing NRI tax clients — I'll help frame Investment Policy considerations: India-allocation thresholds, currency-hedging principles, rebalancing rules, and pre-return planning to lock in beneficial cost-bases on NRE assets. This is structuring and framework discussion, not securities advice. I am not registered with SEBI as an Investment Adviser; for executable, individualised investment advice I refer clients to a SEBI-RIA.
Tax-efficient sale of Indian immovable property by NRIs — including TDS under Section 195 of the 1961 Act (Section 393 of the Income-tax Act, 2025), Form 13 lower-deduction certificates, and capital-gains exemption planning. Succession structuring for the Indian assets of NRI families (will-based and trust-based).
NRIs are taxed in India only on income that accrues, arises, or is received in India — Indian rental, Indian capital gains, Indian salary, interest from NRO accounts, and similar. Foreign income, including foreign salary, is outside the Indian net for the year of NRI status.
The catch is residential status itself: 182-day, 60-day, and 'Deemed Resident' tests under Section 6 of the Income-tax Act, 1961 (carried forward as Section 6 of the Income-tax Act, 2025) can pull you in unexpectedly. Getting status right for each tax year is the foundation of the rest of the file.
Often, yes. Tax treaties between India and most major jurisdictions cap rates on dividends, interest, royalties, and capital gains.
For dividends from Indian companies, treaty rates are usually 10–15% versus the 20% domestic rate. For capital gains on Indian shares, Mauritius, Singapore, and certain other treaties offer favourable terms — though these have been substantially narrowed since 2017. Treaty benefit requires a TRC and Form 10F, claimed under Section 90 / 90A of the 1961 Act (Sections 159 / 160 of the Income-tax Act, 2025), and the documentation must be in order before the income is received.
Up to USD 1 million per financial year can be repatriated from NRO balances under the LRS-equivalent NRI route — backed by Form 15CA (self-declaration) and 15CB (CA certificate).
Source of funds matters: sale proceeds, rent, dividends, and inheritance follow different documentary trails. Get the paper trail in order before applying — the bank will scrutinise it.
NRE accounts hold foreign income in INR — fully repatriable, interest is tax-free in India. NRO accounts hold India-source income — partially repatriable (up to USD 1 million/year), interest is taxable. FCNR accounts hold foreign-currency deposits — fully repatriable, interest tax-free.
Choosing the right mix for your inflows is a small but compounding decision. Misclassification leads to recurring problems at repatriation.
Only incidental to the tax / FEMA engagement, and only for existing tax clients. I am not registered with SEBI as an Investment Adviser, Research Analyst, or Portfolio Manager, and I do not provide standalone, executable, or individualised investment advice.
What I can usefully discuss as part of the broader engagement is structuring: India vs overseas allocation thresholds, the tax-efficiency implications of different vehicles (PMS, MF, direct equity, debt funds), and pre-return cost-base planning. The CFA Charter helps me have the conversation in the right vocabulary, but the actual investment decisions — and their execution — should be made with a SEBI-registered Investment Adviser.
The first call is unhurried, confidential, and at no charge.
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